Who’s on the Hook for Routed Export Violations?

July 29, 2014

By Michelle Kelley

U.S. exporters can be held criminally responsible for export control violations stemming from routed export transactions, according to U.S. government officials at a recent export enforcement panel in Washington D.C.

When a foreign entity controls the transportation of U.S. exported goods, the U.S. government considers the shipment to be a routed export transaction.

Exporters engaging in these types of transactions need to also keep in mind that they are on the hook if a violation occurs, such as a licensing or classification error. As one State Department official pointed out: “You’re the one with all the records. You’re the one responsible.”